CIvPro Complaint

Republic of the Philippines
MUNICIPAL TRIAL COURT IN CITIES (MTCC Br. 2)

City of San Fernando, La Union
HERMIONE GRANGER
Plaintiff,
-versus- Civil Case No. 201-06____

For: Unlawful Detainer
RONALD WEASLEY,
Defendant.
x- - - - - - - - - - - - - - - - - - - -/
COMPLAINT
PLAINTIFF, by counsel, and unto this Honorable Court, most

respectfully allege:
-THAT-
1. Plaintiff is of legal age, Filipino, with residence and postal address

at Apartment A, Lingsat, City of San Fernando, La Union where she may
be served notices and other court processes;
2. Defendant is of legal age, Filipino, with residence and postal address

at Apartment B, Lingsat, City of San Fernando, La Union, or in Gaya-
Gaya, City of San Jose Del Monte, Bulacan, where he may be served
summons and other court processes;
3. Plaintiff is the absolute owner and lessor of that certain apartment duplex
complex situated at Lingsat, City of San Fernando, La Union, and now
leased and occupied by the Defendant;
4. The Defendant leases and occupies the said apartment duplex complex
from January 15, 2021 until December 15, 2021 as agreed upon between
the plaintiff and the Defendant in the lease contract executed on January 8,
2021 under the express obligation to pay a monthly rental of
P20,000.00; (Contract of Lease attached as Annex “A”)
5. The lease contract of the Defendant for the occupation of the building has
been terminated on January 1, 2022 and has not been renewed or extended;
6. During the course of the Defendant’s occupation of the said townhouse,

Defendant has failed to pay his rentals for the months of September 2021 to
December 2021;
7. Defendant has continued to occupy the said townhouse notwithstanding the

fact that her contract of lease has been terminated on January 1, 2022 thus
depriving the plaintiff from having the said duplex complex leased by other
persons;
8. Upon confrontation with the Defendant, Plaintiff noticed that the occupied
Apartment was in a decrepit condition by which Defendant was with a certain
Harry. The Defendant was hysterical when spoken to, responded with
heated shouting and crying that made the Plaintiff leave the apartment;
9. Several demands to vacate was made by plaintiff to Defendant, both oral

and written (Demand letter attached as Annex “B”), but Defendant refused
to vacate the said townhouse and return possession to the plaintiff;
10. Until now Defendant still refuses to vacate and restore possession and pay
her rentals for the months September 2021 to December 2021 during her
occupation of the townhouse;
11. Thus, Defendant is unlawfully withholding possession of the subject

townhouse from the plaintiff despite last and final demand, to the damage
and prejudice of the plaintiff;
12. Before filing of this complaint, the dispute has been referred to the Lupong
Tagamayapa of Lingsat, City of San Fernando, La Union, but the parties
failed to arrive at an amicable settlement; (Certificate to File Action attached
as Annex “C”)
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that after due notice and hearing, judgment be rendered
in favor of Plaintiff:
1. For the restitution of the abovementioned duplex complex;
2. For the payment of SIXTY THOUSAND (PhP60,000.00) PESOS,

representing the arrears of rent now overdue;
3. To pay the costs for this suit.
Other reliefs just and equitable under the premises are likewise prayed
for.
Hall of Justice, Brgy Sevilla, City of San Fernando, La Union,

PHILIPPINES on 24th February, 2022.
FERNANDEZ LAW OFFICES

Atty. R. Francis C. Fernandez
102 Fernandez Bldg., Zamora Extn.,
Dagupan City, Pangasinan
For the Firm:
Atty. R. Francis C. Fernandez

Roll No.: __70381___
PTR No: 3465981_Jan 3 2022__CC
IBP Lifetime No.: __001817 Dagupan City
MCLE Compliance No.: UI - 0031____
Republic of the Philippines)
City of San Fernando (LU)……………………)S.S.
VERIFICATION AND CERTIFICATION

AGAINST FORUM SHOPPING
I, _____HERMIONE GRANGER_______ of legal age, single and a resident
of _Apartment B, Lingsat, City of San Fernando, La Union, after having been
duly sworn to in accordance with law hereby depose and say: That I am the
Plaintiff in the above-entitled civil case, and I have caused the preparation of
the foregoing formal complaint affidavit; I have read and understood its
content and the same are true and correct of my own personal knowledge
and based on authentic records;
That pursuant to Rule 7 of the 1997 Rules of Civil Procedure and existing
Supreme Court circulars, I have not heretofore commenced any other
case/action or proceedings involving the same issues before this office, in
any judicial, quasi-judicial, or other administrative court or agency, and
disciplinary tribunal or authority, and that to the best of my knowledge no
such action or other Cities/Municipalities, in any judicial, quasi-judicial,
administrative and disciplinary authority;
That if I should thereafter that a similar action or proceedings has been filed
or is pending before this office, on in a different judicial, quasi-judicial or
administrative and disciplinary authority of other Cities/Municipalities, I
undertake to promptly inform the said offices/agencies of that fact within five
(5) days therefrom.
IN WITNESS WHEREOF I have hereunto affix my signature in this document
this _24th___ day of _February_, _2022_, here at City of San Fernando, La
Union, Philippines.
________________________
Affiant
TIN 005-612-054-000
Issued in City of San Fernando,
La Union, on Feb 3, 2010
SUBSCRIBED AND SWORN to before me this _24th __ day of February,
2022 at City of San Fernando, La Union, Philippines. The affiant exhibited to
me his/her competent proof of identification TIN 005-612-054-000 as
competent proof of his identity.
NOTARY PUBLIC
Doc No. ______
Page No. ______
Book No. ______
Series of ______

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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES (MTCC Br. 2)

-versus- Civil Case No. 201-06____

PLAINTIFF, by counsel, and unto this Honorable Court, most

1. Plaintiff is of legal age, Filipino, with residence and postal address

2. Defendant is of legal age, Filipino, with residence and postal address

6. During the course of the Defendant’s occupation of the said townhouse,

7. Defendant has continued to occupy the said townhouse notwithstanding the

9. Several demands to vacate was made by plaintiff to Defendant, both oral

11. Thus, Defendant is unlawfully withholding possession of the subject

WHEREFORE, premises considered, it is most respectfully prayed of

1. For the restitution of the abovementioned duplex complex;

2. For the payment of SIXTY THOUSAND (PhP60,000.00) PESOS,

3. To pay the costs for this suit.

Hall of Justice, Brgy Sevilla, City of San Fernando, La Union,

FERNANDEZ LAW OFFICES

For the Firm:

Atty. R. Francis C. Fernandez

VERIFICATION AND CERTIFICATION

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